This week I received a call from a client who had yet another visit from OSHA regarding COVID-19 complaints, but this time the CSHO was an experienced safety professional who peeled that onion back a few more layers and thus she was recommending a serious violation of HAZCOM related to the COVID-19 safety program. What […]
Back in my HAZMAT days, we did a lot of transfers from damaged containers to proper containers to mitigate the release of hazardous materials. When the HAZMAT was a flammable liquid, we oftentimes had to construct our own grounding grid. This was more than not a massive challenge for us as we did this all
The United States Coast Guard (USCG) has issued a Safety Alert to emphasize the importance of properly installed and maintained listed or certified safe electrical equipment in hazardous areas in order to reduce the risk of fire or explosion on board vessels. The publication follows an increasing number of instances by the Coast Guard where
This citation is what we call a “gimme” as this can be found at just about every workplace that has loading docks. We have written this up many times during our S&H audits, only to get some lovely looks and compliments from the facility personnel. Many seem to think that if the dock is only
First, let me state that this construction standard has never been cited. This is based on my personal knowledge and the OSHA database; however, it is still in effect and could be cited. Last year, OSHA revised their standards and they simply did away with the duplicate language in 1926.64 and said to follow the
Many large scale processes that use Cat 1, 2, and 3 flammable liquids may also rely on a Nitrogen purge system to ensure the space within the process vessel is BELOW the Limiting Oxidizer Concentration (LOC) – sometimes called the Minimum Oxygen Concentration (MOC). This safety system is based on the simple fact that if
Many of us use Safety Data Sheets (SDS) on a regular basis and most of us have come to the realization that these documents fall far short of providing us the safety information we really need. For example, when working with flammable liquids do you trust the SDS data to provide an accurate Flash Point
Bonding and grounding is a critical safety function when transferring flammable liquids. But for the ground to function properly, how good must it be or in technical terms, how much resistance to ground is acceptable in the design of the safety system?
Although anhydrous ammonia is an effective refrigerant, it is also a toxic chemical that can injure or kill people when accidentally released. The death of a worker at a Seafood plant in South Boston in 2016 is the most tragic example recently here in New England. In 2018, the U.S. Environmental Protection Agency (EPA) launched a
The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR §68.95, which MUST include: an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date. But do all facilities subject
Respondent owns and operates an agricultural chemical manufacturing facility. On November 2, 2017, Respondent had an accidental release of chlorine at the Facility. Respondent determined the amount of chlorine released to be 0.014 pounds and reported that the release occurred when hooking up a rail car containing chlorine in which an unloading valve was inadvertently
Must an owner or operator conduct and document a compliance audit at the time of an update required under §68.190 if the update is made within three years of the original RMP submission?
